UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**


### HiFlite Productions LLC
**FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS**  **SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Inspire 1UN** 
**** **MANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)** 

___________________________________________________________________________

Submitted on August 12, 2015

Ethan A Gulnac HiFlite Productions LLC 2385 Puu Mala Place, Kihei HI 96753 Tel: (808) 874-3512 Email: hifliteproductions@gmail.com**TABLE OF CONTENTS** GLOSSARY OF ABBREVIATIONS................................................................3 SUMMARY.............................................................................................4 INTRODUCTION AND INTERESTS OF PETITIONER.......................................4 BACKGROUND.......................................................................................4 BASIS FOR PETITION...............................................................................5 NAME AND ADDRESS OF PETITIONER...............................................7 SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH HIFLITE PRODUCTIONS SEEKS EXEMPTION....................................................8 EXTENT OF RELIEF HIFLITE PRODUCTIONS LLC SEEKS AND THE REASON HIFLITE PRODUCTIONS LLC SEEKS THE RELIEF..............11 REASONS WHY GRANTING HIFLITE PRODUCTIONS LLC’ REQUEST WOULD BE IN THE PUBLIC INTEREST...............................................15 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......34 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT NARRATE STUDIOS LLC’S REQUEST.............34 CONCLUSION........................................................................................35**GLOSSARY OF ABBREVIATIONS**
AGL AOI ATC ATO

AV CFR COA FAA FAR GCS GPS LOL NAS NOTAM PIC Section 333 SO SOP UA UAS VFR VLOS VMC VTOL Above Ground Level Area of Interest Air Traffic Control Air Traffic Organization Aerial Vehicle Code of Federal Regulations Certificate of Authorization Federal Aviation Administration Federal Aviation Regulation Ground Control Station Global Positioning System Loss of Link National Airspace System Notice to Airman Pilot In Command FAA Modernization and Reform Act of 2012 (FMRA) Section 333 Safety Observer Standard Operating Procedures Unmanned Aircraft Unmanned Aircraft System Visual Flight Rules Visual Line of Site Visual Meteorological Conditions Vertical Takeoff and Landing**SUMMARY** Ethan A. Gulnac seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b),

to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit HiFlite Productions LLC to op

erate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, special events, film sets, and landscape over certain areas of the United States.

**INTRODUCTION AND INTERESTS OF THE PETITIONER** HiFlite Productions LLC strives to provide its clients with the highest quality digital content for use in their commercial, personal, and non-profit multimedia projects. HiFlite Productions LLC has over 10 years recreational/hobby experience in all aspects of aerial video and photography.

The objective of HiFlite Productions LLC aerial video and photography operations is to pro

vide high quality imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Aerial event photography

• Real Estate Marketing

• Aerial event filming

• Film production

• Aerial location scouting and safety inspection

• Increase public knowledge of UAS and promote safe UAS operations.**BACKGROUND**

Unmanned Aircraft Systems: DJI Inspire 1 HiFlite Productions LLC seeks an exemption to operate DJI Inspire 1 for compensation or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Un

manned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or

smart phone systems. The DJI Inspire 1 has a maximum gross weight of approximately 4 pounds and a maximum speed of approximately 40 knots. The DJI Inspire 1 is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. **UAV Details** Make: DJI Innovations Model : Inspire 1 Type: VTOL - Quadcopter Rotorcraft Maximum Weight: 4 pounds Maximum Payload: 2 Pounds

The DJI Inspire 1 UA that will be operated by HiFlite Productions LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

**BASIS FOR PETITION** Petitioner, HiFlite Productions LLC, pursuant to the provisions of the Federal Aviation Regula

tions (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Sec

tion 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Adminis

trator to commercially operate the DJI Inspire 1 in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).In consideration of the speed, weight, size, and limited operating area associated with the un

manned aircraft and its operation, HiFlite Productions LLC operation of DJI Inspire 1 meets the

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, HiFlite Productions LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for mainte

nance that only apply to aircraft with an airworthiness certificate. HiFlite Productions LLC submits that the requested relief is proper since an equivalent level of safety will be ensured. HiFlite Productions LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, HiFlite Productions LLC will docu

ment and maintain all maintenance records for the DJI Inspire 1. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by HiFlite Productions LLC to the extent nec

essary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, aswell as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a manner consistent with this exemption, including evasive and emergency maneuvers and main

taining appropriate distances from people, vessels, vehicles and structures. HiFlite Productions LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness ,

because the DJI Inspire 1 does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, HiFlite Productions LLC submits that it will ensure that the DJI Inspire 1 are in an airworthy condition, prior to every flight, by determining that the UA are

in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction Manual), and that the aircraft are in a condition for safe flight. HiFlite Productions LLC also seeks an exemption from the requirements of Section 91.121, en

titled Altimeter Settings , as the DJI Inspire 1 will not have a typical barometric altimeter on

board. However, altitude information of the DJI Inspire 1 will be provided to the PIC via Glob

al Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude infor

mation, combined with HiFlite Productions LLC’s operation of the DJI Inspire 1 within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.Additionally, HiFlite Productions LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions . HiFlite Productions LLC submits that safety will not be affected by operation of the DJI Inspire 1 during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough bat

tery power to fly for a total duration of approximately 13.5 minutes to the first point of intend

ed landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, HiFlite Productions LLC provides the following infor

mation in support of its petition for exemption:

**A. Name And Address Of The Petitioner.** The name and address of the Petitioner and point of contact is: Ethan Gulnac HiFlite Productions LLC 2385 Puu Mala Place Kihei, HI 96753 Tel: (808) 874-3512 Email: hifliteproductions@gmail.com

**B. The Specific Sections Of 14 C.F.R. From Which HiFlite Productions LLC Seeks Ex**
  ** emption. 1. HiFlite Productions LLC Seeks Exemption From The Requirements Of Sec**
  ** tion 61.113(a) And (b).** Section 61.113, entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.**2. HiFlite Productions LLC Seeks Exemption From The Requirements Of Section 91.7(a).** Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

**3. HiFlite Productions LLC Exemption From The Requirements Of Section 91.121.** Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the cur

rent reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

**4. HiFlite Productions LLC Exemption From The Requirements Of Section 91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 min

utes. **5. HiFlite Productions LLC Exemption From The Requirement Of Section 91.405(a).** Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies re

paired as prescribed in part 43 of this chapter[.]**6. HiFlite Productions LLC From The Requirements Of Section 91.407(a)(1)** Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alter

ation , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive mainte

nance, rebuilding, or alteration unless-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chap

ter. **7. HiFlite Productions LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).**  Section 91.409, entitled Inspections , subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had -- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. HiFlite Productions LLC Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).**  Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to ser

vice.(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appli

ance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection re

quired by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives includ

ing, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

**C. The Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Produc**
  ** tions LLC Seeks The Relief.** **1. Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Productions LLC Seeks Relief From Section 61.113(a) And (b).**  Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met cer

tain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire.This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, HiFlite Productions LLC submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to safely operate either the DJI Inspire 1 in a manner consistent with the operations speci

fications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, HiFlite Productions LLC submits that all flights of the DJI Inspire 1, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to HiFlite Productions LLC business; and (2) will not carry passengers or property for compensation or hire. **2. Extent Of Relief HiFlite Productions LLC Seeks And The HiFlite Productions LLC Seeks Relief From Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent re

quired to allow HiFlite Productions LLC to determine that the DJI Inspire 1 are in airworthy condition prior to every flight by ensuring that the UA is in compliance with the operating doc

uments (i.e., the HiFlite Productions LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1Instruction Manual). HiFlite Productions LLC seeks the requested relief because the DJI Inspire 1 do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, HiFlite Productions LLC will ensure that the DJI Inspire 1 are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 1Instruction Manual) prior to every flight, and further, determine that the aircraft are in condi

tion for safe flight, as stated in the conditions and limitations below. **3. Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Productions LLC Seeks Relief From Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight opera

tions of the DJI Inspire 1, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), HiFlite Productions LLC seeks the requested relief because the DJI Inspire 1’s altime

ter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Inspire 1 are equipped with a barometric pressure sensor and GPS equipment, which auto

matically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS. **4. Extent Of Relief HiFlite Productions LLC Seeks And The HiFlite Productions LLC Re**
  ** lief From Section 91.151(b).** Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is re

quested to the extent required to allow flights of the battery powered DJI Inspire 1 during day

light hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruis

ing speed, to fly after that for at least 4.5 minutes. HiFlite Productions LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the bat

tery powered DJI Inspire 1 will severely constrain the practicality of any aerial video or still photo flight operations that HiFlite Productions LLC proposes to conduct pursuant to this Peti

tion. Significantly, as set forth below, the technical specifications of the DJI Inspire 1, the DJI In

spire 1 operating documents, and HiFlite Productions LLC’s proposed operating limitations, ensure that HiFlite Productions LLC will safely operate the battery powered DJI Inspire 1 dur

ing daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first point of intend

ed landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. **5. Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Productions LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And**  **91.417(a) & (b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Narrate Studios LLC requests relief from these Sec

tions because the DJI Inspire 1 does not require airworthiness certificates. As set forth more fully below, the DJI Inspire 1 meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, HiFlite Productions LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the meth

ods, techniques, and practices prescribed in the UAS operating documents (i.e., the HiFlite Productions LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 In

struction Manual).**D. The Reasons Why Granting HiFlite Productions LLC Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.**  Granting the present Petition will further the public interest by allowing HiFlite Productions LLC to safely, efficiently, and economically perform aerial video and photography of special events, film sets, and landscape over certain areas of the United States. Additionally, use of the DJI Inspire 1 will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of HiFlite Productions LLC’s proposed operation of the DJI Inspire 1US will be realized without implicating any pri

vacy issues.

**1. The Public Will Benefit From Decreased Congestion Of The NAS.** The DJI Inspire 1 are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Inspire 1 would reduce the amount of manned aircraft in the NAS, reduce noise and air pollu

tion, as well as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight op

erations. **2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1.** Conducting aerial acquisitions with the DJI Inspire 1, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the DJI Inspire 1 produce no air pollution, and is the most viable environmen

tally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery pow

ered electric motors, rather than an internal combustion engine.By using the DJI Inspire 1 to perform aerial acquisitions, the substantial risk to life and proper

ty in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Inspire 1 (weighing approximately 2 pounds has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). **3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 Will Benefit The Economy.**  In addition to being safe and efficient, the DJI Inspire 1 is also an economical alternative to us

ing manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 will allow United States based companies, like HiFlite Productions LLC, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded avia

tion fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Inspire 1 is one such technolo

gy that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI Inspire 1, companies such as HiFlite Productions LLC, can remain com

petitive and profitable, and therefore, provide greater job stability to employees and contrac

tors, which will ultimately contribute to growth of the U.S. economy. Improved financial per

formance of U.S. companies, through commercial use of the DJI Inspire 1, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. **4. There Are No Privacy Issues.** Similar to the manned aerial acquisition flight operations that have been conducted for decades, HiFlite Productions LLC proposed operation of the DJI Inspire 1 will not implicate any privacy issues. Specifically, the DJI Inspire 1 will be operated only in compliance with operating doc

uments (i.e., the HiFlite Productions LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.**E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided**  **By The Rule From Which HiFlite Productions LLC Seeks Exemption. 1. Reasons Why The DJI Inspire 1 Meet The Conditions Of The FAA Modernization and**  **Reform Act of 2012 (FMRA) Section 333.** In consideration of the size, weight, speed, and limited operating area associated with the un

manned aircraft and its operation, HiFlite Productions LLC operation of the DJI Inspire 1 meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accor

dance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance re

quired by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, op

erational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.--If the Secretary determines under this section that cer

tain unmanned aircraft systems may operate safely in the national airspace system, the Secre

tary shall establish requirements for the safe operation of such aircraft systems in the national airspace system.In seeking this exemption, HiFlite Productions LLC submits that the DJI Inspire 1 can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 1; (b) the pilot certification requirement; and (c) the specific operating limita

tions. **a. The Specifications Of The DJI Inspire 1 Demonstrate Its Safe Characteristics.** The DJI Inspire 1 does not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

**i. Technical Specifications Of The DJI Inspire 1.** The technical specifications of the DJI Inspire 1 is set forth by the DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A.

**ii. The DJI Inspire 1 Autonomous Flight And Navigation Modes Enable The UAS To Re**
  ** main Within A Defined Operational Area.** The DJI Inspire 1 may be operated in both manual and fully autonomous flight modes. A com

plete description of the flight and navigational modes of the DJI Inspire 1 is provided at pages 25-35 of the DJI Inspire 1User Manual, attached hereto as Exhibit B.

**iii. The DJI Inspire 1 Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.**  When the Control Link is lost, the DJI Inspire 1 will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Inspire 1 does not reacquire control link data from the GCS, the UA will assume that the Control Link is lost and the UA will return to the home posi

tion (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A complete description of the Failsafe Functions of the DJI Inspire 1 are set forth at pages 27 through 29 of the DJI Inspire 1User Manual, attached here to as B.**iv. The DJI Inspire 1GCS And Its Operation.** A complete description of the operation and specifications of the DJI Inspire 1GCS and flight control software is provided at pages 32 through 43 of the DJI Inspire 1User Manual. DJI In

spire 1User Manual is attached hereto as Exhibit B. **b. Flight Operations Of DJI Inspire 1 Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.**  HiFlite Productions LLC will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1. Additionally, a safety observer will assist all pilots during flight time. **c. Flights Of DJI Inspire 1 Will Be Conducted Pursuant To Specific Operating Limita**
  ** tions.**

In seeking this exemption, proposes to commercially operate DJI Inspire 1 for the special pur

pose of conducting aerial video and photography over certain areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft de

scribed in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Inspire 1Unmanned Aircraft. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the pur

pose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 4. The UAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted dur

ing flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS opera

tions and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating docu

ments. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and re

vised documents if it petitions for extension or amendment to the grant of exemption. If the op

erator determines that any update or revision would affect the basis upon which the FAA grant

ed the exemption, then the operator must petition for amendment to its grant of exemption. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the air

craft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an en

try in the aircraft records.
12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the op

erating documents.13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.
14. The operator must carry out its maintenance, inspections, and record keeping require

ments, in accordance with the operating documents. Maintenance, inspection, alter

ations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signa

ture of the authorized person returning the UAS to service.
15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.
16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.
17. The PIC must possess at least a private pilot certificate and at least a current third- class medical certificate.
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner con

sistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and expe

rience-building flights, all persons not essential for flight operations are considered non

participants, and the PIC must operate the UA with appropriate distance from nonpartic

ipants in accordance with 14 C.F.R. § 91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that air

port’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.
21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontal

ly from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UA loses communications or loses its GPS signal, it must return to a pre- deter

mined location within the planned operating area and land or be recovered in accordance with the operating documents.
23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents.
24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intend

ed landing point and land the UA with 25% battery power remaining.
25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemp

tion. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO is

sued COA including class of airspace, altitude level and potential transponder require

ments. 26. All aircraft operated in accordance with the exemption must be identified by serial num

ber, registered in accordance with 14 C.F.R. part 47, and have identification (N- Num

ber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and con

trol of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehi

cles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where non

participating persons leave such protection and are within 500 feet of the UA, flight op

erations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).
32. All operations shall be conducted over private or controlled-access property with per

mission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.
33. Any incident, accident, or flight operation that transgresses the lateral or vertical bound

aries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.**2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety.**  HiFlite Productions LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 1 unless that PIC has demonstrated, by meeting minimum flight-hour and currency require

ments, that the PIC is able to safely operate the DJI Inspire 1 in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering HiFlite Productions LLC proposed area of operations, and the operating limita

tions set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Inspire 1, HiFlite Productions LLC submits that the additional manned airmanship experience of a commercially certificated pilot would not corre

late to the airmanship skills necessary for HiFlite Productions LLC specific proposed flight op

erations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in cir

cumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). HiFlite Productions LLC will not allow any PIC to operate the DJI Inspire 1 unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 training and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for opera

tions under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during HiFlite Productions LLC proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations un

der the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotor

craft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and land

ings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build profi

ciency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applic

able regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience-building flights the PIC is required to oper

ate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, HiFlite Productions LLC will ensure safe operations by not allowing any PIC to operate the DJI Inspire 1 unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety.**  The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, HiFlite Productions LLC will ensure that the DJI Inspire 1 is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).**4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.**  The equivalent level of safety established by Section 91.121 will be maintained because the al

titude information of the DJI Inspire 1 will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UAS to the GCS for ac

tive monitoring of the flight path and altitude. This altitude information, combined with HiFlite Productions LLC’s operation of the DJI Inspire 1 within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.**  A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1; (2) the lim

itations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, HiFlite Productions LLC will ensure that it will safely operate the battery pow

ered DJI Inspire 1 during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1; the limita

tions on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Inspire 1 provide audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Inspire 1 will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, includingExemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those pre

sented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.**  In seeking this exemption, HiFlite Productions LLC submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because HiFlite Productions LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operat

ing documents (i.e., the HiFlite Productions LLC Aerial Operations Manual, Monthly Mainte

nance Log, and DJI Inspire 1 Instruction Manual). Furthermore, HiFlite Productions LLC will document and maintain all maintenance records for the DJI Inspire 1. Since the DJI Inspire 1 will be inspected as prescribed by the operating documents, HiFlite Productions LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1User Manuals are attached hereto as Exhibit B; a copy of the DJI Inspire 1 Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because HiFlite Productions LLC will use trained technicians to perform maintenance, alterations or preventive mainte

nance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 will be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered. In consideration of HiFlite Productions LLC proposed operating limitations, the operating doc

uments, and the technical aspects of the DJI Inspire 1, HiFlite Productions LLC submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a),91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented here

in (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). **7. The FAA May Prescribe Any Other Conditions For Safe Operation.** In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, HiFlite Productions LLC requests that the FAA prescribe special conditions for the intended operation of the DJI Inspire 1, which contain such safety standards that the Administrator finds necessary to establish a level of safety equiv

alent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UA for the limited purpose of con

ducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will cre

ate a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Inspire 1, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special condi

tions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).**F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which HiFlite Productions LLC Seeks Exemption:**  HiFlite Productions LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

**A Brief Description Of The Nature Of The Exemption HiFlite Productions LLC Seeks:** This exemption will permit HiFlite Productions LLC to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. **G. Any Additional Information, Views, Or Arguments Available To Support HiFlite Pro**
  ** ductions LLC Request.** This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may op

erate safely in the NAS. As such, HiFlite Productions LLC request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, HiFlite Productions LLC will operate the DJI Inspire 1 safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.**CONCLUSION** As set forth herein, HiFlite Productions LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will per

mit safe operation of the DJI Inspire 1 commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing HiFlite Productions LLC to safely, efficiently, and economically op

erate the DJI Inspire 1 commercially within the NAS.
**WHEREFORE** , in accordance with the Federal Aviation Regulations and the FAA Moderniza

tion and Reform Act of 2012, Section 333, HiFlite Productions LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sec

tions 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Inspire 1 commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: August 11, 2015
Respectfully submitted, Ethan Gulnac

Ethan Gulnac HiFlite Productions LLC 2385 Puu Mala Place Kihei, HI 96753 Tel: (808) 874-3512 Email: hifliteproductions@gmail.com